Volkswagen

Reference: page 242

Volkswagen AG and the Group are managed by the Board of Management under the Articles of Association and rules of procedure set by the Supervisory Board. Responsibilities are divided among ten Board functions, with the Chairman holding cross-functional overall responsibility for sustainability and a Chief Sustainability Officer at Group level. As of December 31, 2024 the Board of Management had nine members; the proportion of women was 11.1%. The Supervisory Board has 20 members, split equally between shareholder and employee representatives, with the State of Lower Saxony entitled to appoint two shareholder representatives. Under the ESRS definition, 15 of 20 members are independent (75%), and 40% are women. Board appointments consider diversity, management experience and sector and sustainability expertise. The Supervisory Board collectively holds expertise on sustainability issues including resources, supply chains and sustainable technologies.

Reference: page 248

The Board of Management regularly addresses the results of the interdisciplinary core sustainability processes to obtain an overview of sustainability performance. In the 2024 reporting year the Group Board of Management confirmed the results of the double materiality assessment, and the Audit Committee of the Supervisory Board also considered them. These results were compared with the objectives of the regenerate+ Group sustainability strategy to review its resilience and ensure identified impacts, risks and opportunities are addressed. The Supervisory Board supervises and advises the Board of Management and is directly involved in fundamental decisions through its consent requirement, with supervision covering sustainability topics. The Audit Committee deals with the audit and monitoring of the sustainability report. The Supervisory Board has appointed an ESG officer, currently Hans Dieter Pötsch. Regular status reports keep the Supervisory Board informed; external experts are consulted when necessary.

Reference: page 245

Board of Management remuneration, based on the system adopted in 2020 and revised for 2024, comprises fixed components and variable components: an annual bonus with a one-year assessment period and a performance share plan with a four-year assessment period. The annual bonus is tied to financial targets (net cash flow in the Automotive Division and operating return on sales) plus achievement of ESG sustainability objectives applied through an ESG multiplier factor. The ESG factor covers a decarbonization index, a diversity index and a governance factor. For 2024 the social subtarget used the diversity index only, suspending the opinion survey. Reported 2024 outcomes: decarbonization index actual 46.4 t CO2e/vehicle (target achievement factor 0.8) and diversity index actual 168.0 (factor 1.3). The governance factor was set at the standard value of 1.0 for all members. These ESG factors are allocated to topics identified as material.

Reference: page 444

Volkswagen presents its statement on due diligence in an annex to the Sustainability Report (page 444), in line with ESRS 2 GOV-4, which maps the core elements of the due diligence process to the relevant sections of the sustainability statement. Within the body of the report, human rights due diligence is integrated across the Group through the compliance management system, which regulates compliance with human rights due diligence and is described in the "Employees and non-employees" chapter, and through the responsible supply chain system (ReSC system), implemented in 2022 and described in the "Workers in the value chain" chapter. The ReSC system aims to identify particularly high risks in the supply chain relating to human rights violations and the environment and to manage them appropriately. Validation of the materiality assessment from a human rights perspective considered the severity of negative human rights impacts.

Reference: page 252

The Volkswagen Group's risk management system (RMS) and standardized internal control system (ICS) aim to identify potential risks early so countermeasures can avert losses. The standardized ICS sets requirements in 26 catalogs of controls covering process risks and control objectives, addressing financial reporting, development, production, compliance and sustainability. To safeguard sustainability reporting, material risks along the reporting process were identified in a risk analysis in the reporting year and mitigating controls implemented via a dedicated catalog of controls. Risks span scope completeness, the materiality assessment, identified impacts, risks and opportunities, and the completeness and accuracy of external reporting. A risk-oriented policy addresses incorrect calculation or processing of datapoints. The ICS provides for regular review, identification and rectification of control weaknesses, with quarterly reports to the Board of Management and Audit Committee. External experts assist on a case-by-case basis.

Reference: page 230

Volkswagen AG is the parent of the Volkswagen Group, a leading multibrand automotive group with Automotive and Financial Services divisions. The Automotive Division spans Passenger Cars, Commercial Vehicles and Power Engineering business areas; Financial Services covers dealership and customer financing, leasing, direct banking, insurance and mobility services. The Group employed 614,082 people at the end of 2024 and serves customers in markets worldwide. The value chain is broadly distributed and increasingly vertically integrated: the upstream segment covers raw material extraction and component production; the core business covers vehicle development, production and sale; and the downstream segment covers the use phase and end-of-life management including recycling. In 2024 Volkswagen developed The Group Strategy - Mobility for generations, with the regenerate+ Group sustainability strategy enshrined within it across four dimensions: nature, our people, society and business.

Reference: page 240

Volkswagen defines stakeholders as individuals, groups or organizations that influence or are influenced by corporate decisions, and has identified ten key stakeholder groups, with employees and customers at the center, plus eight further groups from continuous analysis. The Supervisory Board and Works Council act as supervisory and advisory bodies and as interfaces between internal and external stakeholders; the Supervisory Board is regularly informed of stakeholder views on sustainability-related impacts. In the reporting year the stakeholder engagement strategy was developed into a relationship strategy with new interactive formats. Engagement is guided primarily by the Group strategy. The Group Sustainability Forum was held in Berlin in October 2024, and the independent Group Sustainability Council was reorganized into twelve external experts across the four regenerate+ dimensions, working with internal representatives in Sustainability Practice Groups and sharing results with the Board of Management.

Reference: page 253

Through the double materiality assessment, 28 of the 38 topics considered were identified as material. A total of 17 positive impacts, 19 negative impacts, 8 risks and no opportunities were categorized as material (44 IROs in total). These material impacts, risks and opportunities were assigned to the subtopics of the ESRS, mapping to the environmental standards E1 to E5, social standards S1, S2 and S4, and governance standard G1, plus the entity-specific topic of Corporate Citizenship. Only the impact of Corporate Citizenship is covered by additional entity-specific information; the standard ESRS S3 Affected Communities was not material. The option to present material impacts, risks and opportunities under the respective topical standards was applied for 2024, with current material financial effects described in those chapters. Results were compared with regenerate+ and the Group risk management, and resilience analyses were carried out for E1 and E4.

Reference: page 249

Volkswagen performed double materiality assessments for fiscal year 2024 covering its own operations and the upstream and downstream value chain, taking a global view. A methodology established in 2023 set standardized steps and criteria. The process has four steps: analysis of context, collection of impacts, risks and opportunities, assessment, and validation. The 37 ESRS subtopics plus the entity-specific Corporate Citizenship topic gave 38 topics. Impact materiality assessed scale, scope and irremediable character for severity, multiplied by likelihood; impacts are material at a risk score of 50 or above on a scale of 1 to 100. Financial materiality scores combine likelihood with severity (financial and reputational effects); risks and opportunities are material at a score of 50 or above or a financial effect of 1 billion euros or more. Stakeholder concerns were integrated indirectly via in-house experts; direct consultations did not take place. Results were validated, including from a human rights perspective, and approved by the Board of Management.

Reference: page 253

Volkswagen identified the relevant ESRS disclosure requirements on the basis of the material impacts, risks and opportunities for fiscal year 2024. To determine which information to report, datapoints were first allocated to one or more of the 38 topics; datapoints relating exclusively to immaterial topics were excluded, voluntary datapoints with phased-in disclosure requirements deemed irrelevant were eliminated, and metrics allocated to a material topic but not categorized as relevant were excluded for documented reasons. With 28 of 38 topics material, the disclosures map to topical standards E1 to E5, S1, S2 and S4, and G1, plus the entity-specific Corporate Citizenship topic; ESRS S3 Affected Communities was not material. The Annex to the Sustainability Report contains a detailed index indicating which ESRS disclosures appear in which section, including an index for datapoints deriving from other EU legislation.

Reference: page 267

Volkswagen targets net carbon neutrality by 2050, aligned with the Paris Agreement 1.5C goal, via a hierarchy of actions prioritizing emission avoidance and reduction before offsetting. Production (Scope 1 and 2) emissions are to fall 50.4% by 2030 versus base year 2018, SBTi-validated as 1.5C aligned, en route to a 90% absolute cut by 2040 and net neutrality at production sites. Use-phase Scope 3 (category 11) for passenger cars and light commercial vehicles is to drop 30% by 2030 versus 2018, SBTi-certified as 2C aligned. Four decarbonization levers drive this: e-mobility (BEV ramp-up via MEB/PPE/SSP platforms), conversion of energy supply to renewables, energy efficiency, and value chain decarbonization. VW notes no Group-wide decarbonization plan under ESRS E1 paragraph 16 yet exists, and TRATON and MAN Energy Solutions lack transition plans (in development). The plan is embedded in Group strategy and regenerate+, funded through medium-term investment planning and a Green Finance Framework (10.5 billion euros in green bonds since 2020). EU Paris-aligned Benchmark exclusions (Annex 12.1) were reviewed and found not to apply; ICE production capacity carries stranded asset risk. Progress: by end 2024, Scope 1 and 2 emissions were already cut 51% versus 2018, meeting the 2030 target six years early.

Reference: page 270

Decarbonization is supported by a Group policy based on scientific principles and the Paris Climate Agreement, derived from the GHG Protocol and SBTi frameworks, with defined climate change mitigation targets to help limit warming to 1.5C. Key supporting instruments include the Group strategy focused on decarbonization, the regenerate+ sustainability strategy, the goTOzero environmental mission statement, and the Code of Conduct for Business Partners. The Group systematically focuses on electrification of products, decarbonization of the entire value chain, and expansion of renewable energy to supply sites and customers, aiming for net carbon neutrality by 2050. Energy and CO2 are focal points of the Zero Impact Factory vision, which targets gradual reduction of absolute environmental impact of production sites by 2050 and at least 60% fulfillment of an internal site checklist by 2030. Energy efficiency is treated as the first lever. On climate change adaptation, the strategic focus is currently primarily on decarbonization; adaptation policies and guidelines tied to supply chain and site risk assessment are being developed and will be integrated into the strategy process in future, with case-by-case countermeasures for high risks. Business partners are required to reduce GHG emissions and use renewable energy.

Reference: page 278

Actions follow four decarbonization levers. E-mobility: around 90% of targeted decarbonization can be realized through fleet electrification and renewable energy; BEVs are built at 18 sites on the MEB and PPE platforms with the SSP in development, and 2024 saw launches including the ID.BUZZ LWB, CUPRA Tavascan, Audi A6 and Q6 e-tron, Porsche Taycan and Macan, plus a software partnership with Rivian. Conversion of energy supply: switching plants to renewables, with Wolfsburg coal blocks retired April 2024, 73 sites on 100% renewable external electricity, 66.9% of global electricity from renewables in 2024, plus owned solar and wind investments. Energy efficiency: 9,113 actions implemented by 2024 saving 3.5 million MWh annually. Value chain decarbonization: PowerCo battery cell production (Salzgitter, Valencia, St. Thomas), supplier CO2e limits, Zero Impact Logistics (rail shift, LNG and biofuel ships), and dealership network decarbonization via goTOzero RETAIL. Resources include the Green Finance Framework, with 1.0 billion euros in green bonds issued in the reporting period and 10.5 billion euros since 2020 to refinance BEV CapEx.

Reference: page 272

The headline targets are a 50.4% absolute reduction in production Scope 1 and 2 GHG emissions by 2030 versus base year 2018 (baseline 9.03 million tons CO2e, market-based, SBTi-validated 1.5C aligned), a milestone toward net carbon neutrality at production sites by 2040, and a 30% reduction in use-phase Scope 3 category 11 emissions for passenger cars and light commercial vehicles by 2030 versus 2018 (baseline 412,986,695 tons CO2e, SBTi-certified 2C aligned). By end 2024, Scope 1 and 2 were already down 51% versus 2018, meeting the 2030 goal six years early. Energy targets to 2030 include saving 4.9 million MWh annually (9,113 actions had achieved 3.5 million MWh by 2024), generating 1.2 million MWh of renewable electricity per year (574,801 MWh in 2024), and sourcing 100% renewable external electricity at all sites except China (94% achieved by 2024; China targets 100% carbon-neutral electricity). The dealership network carbon footprint (2020 base 3.22 million tons) is to fall at least 30% by 2030, 55% by 2040 and 75% by 2050. The decarbonization index averaged 48.0 tons CO2e per vehicle in 2024 (from 48.9 in 2023). Targets are tracked via the SBTi (next audit 2025) and the DCI.

Reference: page 287

Total energy consumption for the Volkswagen Group in 2024 was 19.0 million MWh (19.4 in 2023), or 24.6 million MWh including companies with operational control (5.5 million MWh). Energy from fossil sources was 11.9 million MWh, comprising natural gas (8.7), crude oil and petroleum products (1.1), coal and coal products (0.8), purchased fossil energy (1.2) and other fossil fuel (0.1). Nuclear sources contributed 0.04 million MWh and renewable sources 7.1 million MWh (5.9 in 2023), of which 6.0 was purchased renewable energy (5.7 of it electricity) and 1.0 was renewable fuel. Of purchased renewable electricity, 65.4% was bundled and 34.6% unbundled. Self-generated renewable non-fuel energy was 0.04 million MWh. Energy intensity for high climate impact sector activities was 0.059 kWh per euro of sales revenue, on 19.0 million MWh and 324,656 million euros of revenue (all VW activities fall under NACE C.29.10). Total energy generation was 6.4 million MWh (5.6 non-renewable, 0.8 renewable). 2023 comparatives are voluntary and not externally validated.

Reference: page 288

In 2024 Volkswagen Group Scope 1 GHG emissions were 3.0 million tons CO2e (3.6 in 2023), of which 84.4% fell under a regulated ETS and 0.4 was biogenic. Scope 2 was 2.6 million tons CO2e location-based and 0.5 million tons market-based (2.4 and 0.7 in 2023). Total Scope 3 emissions were 408.58 million tons CO2e (429.12 in 2023), reported across 13 of 15 categories; categories 9 and 10 are folded into categories 4 and Scope 1 respectively, and category 15 is omitted for low materiality. The use phase (category 11) was 296,904,121 tons CO2e (72.7% of Scope 3, well-to-wheel, 200,000 km lifetime), and purchased goods and services (category 1) was 87,346,897 tons (21.4%). Total GHG emissions were 416.1 million tons CO2e location-based and 413.0 million market-based (437.4 and 435.1 in 2023). GHG intensity was 0.8 kg CO2e per euro of revenue on 324,656 million euros. Scope 1 and 2 are calculated per the GHG Protocol and ESRS using VDA emission factors (location-based) and provider-specific factors (market-based). TRATON and MAN Energy Solutions Scope 3 figures are reported separately; no 2023 Scope 3 exists for them.

Reference: page 295

Volkswagen has implemented no actions for GHG removal and storage in its own operations or value chain, so no removal metrics are reported; any future actions would distinguish technology-based solutions (using direct measurement) from nature-based solutions (using established carbon market standards such as VERRA and Gold Standard). Carbon credits enhance the decarbonization strategy and are reserved for hard-to-abate emissions, expected to affect less than 10% of emissions in line with SBTi requirements, and are used to ensure net carbon-neutral delivery of battery-electric vehicles. Only VERRA and Gold Standard credits are used; no others were used in the reporting year. Each credit represents minus 1 ton CO2e and is transferred to Group accounts before use. Total carbon credits canceled in 2024 were 6,076,738 tons CO2e, all from CO2 emission reduction projects (0% from removals), split 70% VERRA (4,232,578 tons) and 30% Gold Standard (1,844,460 tons). VW targets net carbon neutrality by 2050 but notes no binding net zero certification standard yet exists, so it has no specific removal or storage targets and limits offsetting to below 10%.

Reference: page 297

The Volkswagen Group does not currently use an internal carbon price in investment decisions. Instead it applies an abatement cost approach to support strategic decisions and to calculate and prioritize decarbonization actions in production. This relates various GHG emissions to net present value, producing a value in euros per ton of CO2e. The result is an abatement cost curve ranging from savings per ton of CO2e (energy efficiency actions) to high costs per ton of CO2e (use of synthetic fuels). The curve helps prioritize actions and estimate the total costs of achieving the Group's targets. However, this approach is not yet applied within individual investment decisions.

Reference: page 301

Pollution prevention is part of the environmental mission statement goTOzero, anchored in an associated policy stating "We reduce harmful emissions in air, soil and water." Air and water pollution topics are addressed through goTOzero, with the main focus on reducing the discharge of pollutants. The Zero Impact Factory vision targets production facilities that emit as few harmful substances as possible. The Code of Conduct for Business Partners requires partners to avoid harmful soil, water and air pollution. Substances of very high concern are anchored in the Group standard on material and chemical conformity of products, referencing the GADSL and requiring compliance with the Minamata and Stockholm Conventions. Chemical compliance is treated as a crosscutting issue integrated into existing management systems.

Reference: page 304

There is no separate management system for chemical compliance; requirements are met by operating organizations and suppliers under the Three Lines Model of the Institute of Internal Auditors. For emissions to water, the Group discharges no untreated wastewater, using pretreatment plants, separators, evaporators, physico-chemical precipitation for metals and membrane bioreactors to remove phosphorus and nitrogen. For air, actions include VOC-reduced thinners and paints, paint shop VOC requirements and dust restrictions, plus portfolio transformation toward e-mobility to cut nitrogen oxide and particulate emissions. In the upstream value chain the raw materials due diligence management system (RMDDMS) applies, with 18 raw materials identified as particularly risky, including cobalt, lithium, nickel, graphite and the 3TG conflict minerals.

Reference: page 304

The overarching specific UEP metric accounts for VOC emissions from vehicle and components production, directly relating its target to air pollution. The impact points target for reducing absolute environmental impacts of production sites includes emissions into air and water, monitoring VOCs, nitrogen oxides, dust, CHCs and HFCs in air, and chemical oxygen demand, nitrogen, phosphorus, nickel and zinc in water. A site checklist covers VOC-reduced thinners and paints, dust limits, avoidance of heavy metals, and discharge limits for chloride, sulfate, nickel, zinc, manganese and COD. No measurable outcome-oriented ESRS targets have been defined for the prevention and control of substances of very high concern; systematic data collection to enable quantitative reporting is still being developed.

Reference: page 307

Group-wide emissions are reported for sites exceeding E-PRTR thresholds. In 2024, air emissions for the Volkswagen Group were VOC 10,963 tons, CHCs 5.7 tons, HFCs 22.6 tons, NOx 1,126.1 tons, SO2 0.0 tons, dust (PM10) 148.4 tons and CO 0.0 tons. Water emissions were TOC 463.1 tons, zinc 2.2 tons, nickel 2.6 tons and dissolved fluoride 26.6 tons. Group standard 98000 defines the indicators for consistent collection across sites, with parameter-specific measurement methods based on the state of the art. VOC emissions are mainly released during painting processes, while combustion emissions such as NOx, CO and SO2 are calculated from fuel quantities and country-specific emission factors. 2023 comparatives were provided voluntarily and not externally validated.

Reference: page 309

The IMDS-SVHC list of the European Automobile Manufacturers' Association, derived from the ECHA candidate list, is the basis for recording substances of very high concern. A full evaluation of SVHC quantities used or procured cannot currently be carried out at Group level. SVHCs as components of products are calculated for reference vehicles (ID.4 and Tiguan). For 2024, the total SVHCs as product components were 5,421 tons for battery-electric vehicles and 39,672 tons for internal combustion engine vehicles, dominated by substances toxic for reproduction (5,398 and 39,365 tons). The Porsche AG Group reported 2,883 tons. The TRATON GROUP reported 24,780 tons, based on lead content in starter batteries, which make up about 98% of SVHCs in a typical truck.

Reference: page 312

Water management is set out in a dedicated policy, with conservation of water as a resource a key focus. In line with the regenerate+ strategy, the Group works to continually reduce the need for primary raw materials, including water, while the goTOzero mission statement sets goals for improving resource efficiency, promoting reuse and reducing harmful emissions to water. Water is a focal point of the Group-wide Zero Impact Factory vision, which targets reducing water withdrawal, increasing reuse, using water responsibly in areas with water stress, and preventing deterioration of receiving water quality. About two thirds of freshwater is obtained externally and about a third from own wells, rainwater and surface water. The Code of Conduct for Business Partners obliges partners to minimize water consumption, with water-scarce regions taking priority.

Reference: page 314

The Code of Conduct for Business Partners requires partners to continually minimize water withdrawal, focusing on water-scarce regions through reduction, reuse, recycling and effective wastewater treatment. The Responsible Lithium Partnership in Chile, co-founded in 2021 and coordinated by GIZ, is one example, bringing stakeholders together to manage water in the Salar de Atacama, where around a quarter of the world's lithium is extracted. At production sites, continuous optimization of water-saving processes is pursued. About 42.3% (around 14.5 million m3) of Group-wide water withdrawal occurs at sites in high or extreme water stress areas. The San Jose Chiapa site in Mexico is wastewater-free via closed-loop circulation, and Kariega in South Africa expects roughly 15% reduction. About 3.9 million m3 of water was reused in 2024.

Reference: page 313

By 2025, production-related environmental impacts at all passenger car and light commercial vehicle sites are to be reduced by 45% compared with 2010, with the UEP metric including water consumption per vehicle. Water withdrawal at production sites (excluding TRATON GROUP and MAN Energy Solutions) is to be reduced by 30% on average across the Group by 2035 compared with 2018 (baseline 45.6 million m3). At hot spot locations with moderate to extreme water stress, withdrawal is to fall by as much as 40% (baseline 28.1 million m3). In 2024, Group-wide water withdrawal was 32.5 million m3, a 13.1 million m3 reduction versus 2018, equal to 94.9% target achievement. Hot spot site withdrawal was 17.8 million m3, a 10.3 million m3 reduction, equal to 93.2% achievement.

Reference: page 315

Water consumption is calculated as water withdrawal minus volume of wastewater, describing water no longer available for further use, mainly from evaporation losses in production. In 2024, total water consumption for the Volkswagen Group was 8.8 million m3, of which 2.6 million m3 was in areas at water risk, with water intensity of 0.03 l per euro. Total water withdrawals were 21.2 million m3 (4.4 million m3 in areas at water risk), total wastewater discharge was 13.9 million m3 (2.0 million m3 in areas at water risk) and total reused water was 2.7 million m3. About 86% of water withdrawal samples are measured directly. The Verisk Maplecroft water stress index identifies areas at water risk, and 25 production sites are currently considered hot spot sites.

Reference: page 319

A 2024 resilience analysis examined the Group's ability to adapt to material negative biodiversity impacts. It identified no significant physical, transition or systemic risks or opportunities, but confirmed material impacts. The analysis used short, medium and long-term horizons and assessed how strategy and business model address impacts along the value chain. Regenerate+ is the central strategic framework, with nature defined as a core dimension and biodiversity addressed in its ecosystems pillar. Impacts are addressed through policies such as goTOzero and the Biodiversity Commitment plus site actions like insect hotels, nesting boxes and flowering meadows. No specific Group-level biodiversity targets existed for 2024 but are being developed. External stakeholders and indigenous knowledge holders were not included.

Reference: page 322

The Biodiversity policy addresses negative impacts, particularly along the upstream value chain. The Chief Sustainability Officer coordinates biodiversity within regenerate+, while the Group Head of Environment handles production-related biodiversity. The Group has been involved in biodiversity protection since 2007, embedding it in the goTOzero environmental mission statement and the Biodiversity Commitment. As a founding member of Biodiversity in Good Company, it acknowledges the three goals of the Convention on Biological Diversity. Biodiversity is anchored in the Code of Conduct for Business Partners, requiring deforestation-free supply chains. In the reporting year, Volkswagen became the first automotive manufacturer to join the LEAF Coalition. It is also a member of the DRIVE Sustainability Partnership and rolled out the Biodiversity Land Use Indicator in 2024.

Reference: page 324

Sites identify, plan and evaluate their own biodiversity actions, often involving local providers and employees. Examples include flower meadows in Poznan, bug hotels in Crewe, nesting boxes in Barcelona and Wrzesnia, bee colonies in Puebla, and a 30 hectare sheep grazing project in Chattanooga. In Palmela, employees and families planted 2,000 native trees and shrubs and 120 volunteers collected eleven tons of waste. Of more than 200 Corporate Citizenship projects in 2024, over 29 directly promote biodiversity. From 2025 a Sustainability Impact Fund supports internal projects and a biodiversity fund of up to 25 million euros per year funds external projects through 2029. Volkswagen Group China's Green Belt project aims to plant more than 8.5 million trees by 2030.

Reference: page 324

Biodiversity and ecosystems are anchored in regenerate+, the Biodiversity Commitment and the goTOzero environmental mission statement. To record progress, the Group is a founding member of the Biodiversity in Good Company initiative. Biodiversity forms part of the strategic vision of the Zero Impact Factory, for which the Group created a site checklist featuring quantifiable targets. Criteria include consideration of local protected areas and funding for biodiversity and environmental education, plus actions such as planting regional plant species, semi-natural design of green spaces and creating habitats at or near sites. In 2024 a new metric, the Biodiversity Land Use Indicator, was introduced; a specific target for it will be set in the future. This metric aims to increase the proportion and quality of semi-natural areas at sites.

Reference: page 326

As a vehicle and component manufacturer, the Group impacts land use through building and sealing land. The new Biodiversity Land Use Indicator, established at Group level in 2024 for passenger car and light commercial vehicle sites, reports the proportion of semi-natural areas weighted by ecological quality (low, medium or high). These areas may be on-site or within a 30 km radius. The initial Group-wide survey in 2024 showed a result of approximately 28.6 percent, accounting for area quality. An average of about 50 percent of plant area is currently sealed. For sites near or in biodiversity-sensitive areas, a 4.5 km radius was applied: 58 of 117 sites analyzed are near such areas, totaling 8,653 hectares, with 126 protected areas nearby and four sites directly adjacent.

Reference: page 329

Resource use and circular economy are addressed in a corresponding policy whose key elements are closed-loop circulation of materials, joint development of recycling technologies, use of secondary materials, improved resource efficiency, and reuse and recycling of materials and components. Within the nature dimension of regenerate+, the Group works to continuously reduce demand for primary raw materials. Circular economy is a core element of the goTOzero environmental mission statement, and resource efficiency is addressed in the environmental policy and the ECMS. Circularity is built into vehicle development through environmental standards covering recycling requirements, use of recyclates and recyclability type approval, including preferred use of recyclates and ISO-compliant plastics labeling. Resource efficiency, circular economy and waste management are central to the Code of Conduct for Business Partners.

Reference: page 331

Initial circular economy steps focused on batteries, steel, aluminum and plastics. Cross-brand working structures and committees manage the topic, and the Group participates in the Global Battery Alliance (over 140 members) and IRMA. Recycling begins at vehicle development, with plastics labeled to ISO standards for separation. The first battery recycling pilot at Salzgitter, opened in early 2021, is designed to recycle up to 3,600 battery systems per year. The Aluminum Closed Loop project can save up to 95 percent of manufacturing energy versus primary aluminum. At Kassel, nearly 15 tons of aluminum chips are remelted daily. The HVBatCycle research consortium, created in 2023, aims to recover traction battery materials. PowerCo cell factories are designed for closed-loop recycling.

Reference: page 330

The overarching UEP metric includes waste volume for disposal per vehicle, and the Impact Points method covers all production waste, rewarding higher-value treatment. The Group aims to use 40 percent circular materials in its vehicles from 2040 onwards (excluding China). Under the draft regulation on vehicle circularity, from around 2032 new vehicles must contain a specific share of post-consumer plastic recyclate. Under the new Batteries Regulation, from 2031 battery cells must contain 6 percent lithium, 16 percent cobalt and 6 percent nickel from end-of-life batteries or battery production waste. By 2040, 95 percent of direct suppliers (by revenue) should hold a positive S-Rating, with an 85 percent intermediate target for 2025. By 2040, 95 percent of larger production suppliers should hold ISO 14001 or EMAS certification.

Reference: page 337

A vehicle comprises around 10,000 individual parts, and the management system covers 18 raw materials including cobalt, lithium, nickel, graphite and the 3TG conflict minerals. Resource inflows for 2024 were calculated using a reference vehicle approach based on the Tiguan and ID.4. For battery-electric vehicles, total weight of products and materials used was 1,185,989 tons (1,184,705 technical, 1,283 biological); for internal combustion engine vehicles it was 8,639,279 tons (8,622,786 technical, 16,493 biological). Reused or secondary recycled content ranged 12.5 to 24.9 percent for battery-electric vehicles and 16.4 to 26.2 percent for combustion vehicles. Porsche reported 621,679 tons and TRATON 2,473,853 tons. Around 42.3 percent (about 14.5 million cubic meters) of water withdrawal came from high to extreme water-stress areas.

Reference: page 341

Group standard 98000 defines waste indicators collected uniformly worldwide. Under the European end-of-life vehicles Directive, passenger cars and light commercial vehicles must be 85 percent recyclable and 95 percent recoverable; all Volkswagen Group vehicles registered in Europe comply, calculated per ISO 22628. The average end-of-life vehicle age in Europe is 14 to 20 years, with 200,000 km assumed mileage. In 2024 total waste was 2,357,654 tons, of which 2,185,092 tons went for recovery (1,875,417 tons recycled) and 172,596 tons for disposal (144,750 tons landfilled). Non-recycled waste was 310,492 tons, or 13.2 percent of total waste volume; total hazardous waste was 210,023 tons. Main waste streams are scrap metal, plastics, paint sludge, packaging and hazardous waste.

Reference: page 341

Group standard 98000 defines waste indicators collected uniformly worldwide. Under the European end-of-life vehicles Directive, passenger cars and light commercial vehicles must be 85 percent recyclable and 95 percent recoverable; all Volkswagen Group vehicles registered in Europe comply, calculated per ISO 22628. The average end-of-life vehicle age in Europe is 14 to 20 years, with 200,000 km assumed mileage. In 2024 total waste was 2,357,654 tons, of which 2,185,092 tons went for recovery (1,875,417 tons recycled) and 172,596 tons for disposal (144,750 tons landfilled). Non-recycled waste was 310,492 tons, or 13.2 percent of total waste volume; total hazardous waste was 210,023 tons. Main waste streams are scrap metal, plastics, paint sludge, packaging and hazardous waste.

Reference: page 370

Volkswagen manages impacts on employees through Group-wide policies applying to all controlled companies, set out primarily in Group policies and reviewed at least annually. The Group recognizes international frameworks including the Universal Declaration of Human Rights, the ILO Core Labour Standards, the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines. Business and human rights are integrated into the compliance management system to meet due diligence obligations under the German Supply Chain Act (LkSG), using a three-lines-of-defense model. Key policies include the HR Compliance Group policy, the Code of Conduct, and the Group policy on occupational health and safety. These anchor diversity, equal opportunity, anti-discrimination, freedom of association, and prohibition of child and forced labor, and are publicly available on the Group website.

Reference: page 365

Volkswagen maintains continuous dialogue with workers' representatives including works councils, trade unions, and Supervisory Board representation about actual and potential impacts on employees. The Volkswagen AG Supervisory Board has equal representation of employer and worker representatives, enshrined in German law. The Group European Works Council and Global Group Works Council are central tools for incorporating employee interests, meeting in consultative sessions at least once a year. Framework agreements include the Declaration on Social Rights, the Charter on Labor Relations, the Charter on Temporary Work, and the Charter on Vocational Training. An annual opinion survey, used since 2008, collected employee satisfaction data; the 2023 participation rate was 79% at participating companies. The survey was suspended in 2024 for revision, with a new survey planned for 2025.

Reference: page 367

Volkswagen operates a Group-wide whistleblower system as the central point of contact for reporting rule breaches, coordinated by the Central Investigation Office in Wolfsburg, with separate investigation offices at AUDI, Porsche, TRATON, and a regional office in China. Employees, business partners, customers, and third parties can report potential breaches at any time, anonymously if they choose, including serious impacts and human rights violations. The procedure follows the effectiveness criteria of the UN Guiding Principles on Business and Human Rights. Complaints are documented, investigated, and monitored, with remedial action determined case by case. External mechanisms such as the OECD National Contact Point and the German BAFA are also available. A policy protects individuals, including workers' representatives, against retaliation. The proportion of anonymous reports without contact details remains very low.

Reference: page 374

Volkswagen takes action across working conditions, occupational health and safety, equal treatment, and other work-related rights. For working conditions, the budget planning round plans Group-wide plant utilization to stabilize employment, though it could not be completed in 2024 due to collective bargaining lasting until year-end. The Group expanded digital training via the SuccessFactors and Degreed platforms, with Degreed users up over 25% from over 30,000 in 2023. It is committed to freedom of association and makes annual inquiries to risk regions. For health and safety, it requires ISO 45001 certification at production sites with more than 1,000 employees and conducts systematic risk analyses; four Group audits were conducted in 2024. Equal-treatment actions include a new anti-discrimination rule communicated to 106 companies and manager training on unconscious bias.

Reference: page 374

Volkswagen's targets derive from the Group People Strategy and the regenerate+ sustainability strategy; employees and their representatives were not involved in defining them. For training, the Group aims to increase average training hours per employee in the active workforce by 35% to 30 hours per year by 2030 from a baseline of 22.3 hours (2015 to 2019 average); the 2024 target of 26 hours was missed with 20.8 hours achieved. For occupational health and safety, all production sites with more than 1,000 employees are to be ISO 45001 certified by 2026, and the LTIFR is to be reduced below 1 for all brands by 2040. For diversity, the proportion of women in management should reach 20.2% by 2025 and internationality of top management at least 25.0% by 2025. No outcome-oriented targets are set for adequate wages, social dialogue, freedom of association, persons with disabilities, or child and forced labor.

Reference: page 374

Volkswagen employed 614,082 people (headcount) at the end of 2024. By gender: 489,917 male, 124,125 female, 7 diverse, and 33 not disclosed. Permanent contracts covered 591,137 employees and temporary contracts 22,945, with no non-guaranteed hours employees. By region, Germany had 293,338 employees, Europe and other markets 203,424, North America 47,072, South America 31,740, and Asia-Pacific 38,508. The largest country totals were Germany (293,338), Czech Republic (37,005), USA (26,117), Sweden (25,804), China (23,555), Spain (23,064), and Brazil (22,810). In 2024, 37,516 employees left the Group, giving a staff turnover rate of 6.1%. The headcount differs from the Group management report figure because the latter includes the Chinese joint ventures.

Reference: page 374

Volkswagen reports that non-employees in its own workforce include self-employed people and people provided by undertakings primarily engaged in employment activities, referred to as temporary external personnel. The total headcount of non-employees working in the Group was 25,162 at the end of the 2024 reporting year. For these non-employees, the Group aims to ensure appropriate working and remuneration conditions. When Procurement hires temporary external personnel, compliance with relevant employment standards is implemented through Procurement's management policies, with the Charter on Temporary Work and the Code of Conduct for Business Partners applying where there are procedural deviations. Temporary external personnel can use the Group's interest representation bodies for topics affecting their employment, provided there are no statutory or company regulations to the contrary.

Reference: page 374

Volkswagen reports, for the first time under the ESRS, that 92.0% of its employees are covered by collective bargaining agreements, with this figure relating only to employees in the European Economic Area (EEA). A total of 99.1% of employees in the EEA are covered by workers' representatives. A collective bargaining agreement is defined as a written agreement between trade unions, or duly elected workers' representatives in their absence, and employers governing working hours and wages as core components. Coverage varies by country: in the 80 to 100% band for collective bargaining are Austria, Belgium, Czech Republic, Finland, France, Germany, Hungary, Italy, Netherlands, Norway, Portugal, Slovakia, Spain, and Sweden, while Bulgaria, Estonia, Ireland, Croatia, Latvia, and Lithuania fall in the 0 to 19% band. Agreements exist for representation by a European Works Council.

Reference: page 385

Volkswagen reports gender distribution at top-management level (including the Group and brand Boards of Management) as of December 31, 2024: 421 male (87.7%), 59 female (12.3%), and 0 other. The distribution of employees by age group was 16.1% under 30 years, 56.9% between 30 and 50 years, and 27.0% more than 50 years. Separately, the proportion of women across management, senior management, and top management combined was 19.9% in 2024, up 0.7 percentage points from 19.2% in the prior year. The internationality of top management stood at 29.1% (prior year 25.6%). These figures feed the diversity index, which reached a score of 168 in 2024 (prior year 154), exceeding the planned value of 149 against a base of 100 set for 2016.

Reference: page 374

Volkswagen uses the statutory minimum wage of each country, or a comparable benchmark, within the EEA, and the Wage Indicator Foundation's Living Wage database for countries outside the EEA, with benchmarks last updated in October 2024. Only base salary and guaranteed additional payments are included in the calculation. Near enough all employees are paid above the respective benchmarks and therefore receive an adequate wage under the ESRS definition. The few exceptions, with the count and proportion of employees paid below the benchmark, were: Singapore 86 of 703 (12.2%), Morocco 6 of 133 (4.5%), Albania 2 of 81 (2.5%), Sweden 49 of 25,804 (0.2%), Austria 5 of 7,938 (0.1%), Mexico 10 of 20,117 (0.1%), Brazil 1 of 22,810 (0.0%), and Germany 2 of 293,338 (0.0%). These employees still receive other remuneration components not counted under the ESRS definition.

Reference: page 374

Volkswagen reports that the average number of training hours per employee in accordance with the ESRS requirements was 18.9 hours in the reporting year. The calculation is based on employee data from December of the previous year to December of the reporting year. Time-bound and non-time-bound classroom and online training, with or without a trainer (self-guided), count as training; for time-bound learning the precise qualification time is recorded, and where that is not technically possible the stored target value per measure is used. This ESRS metric differs from the Group's strategic KPI on training hours (20.8 hours in 2024 against a 26-hour target), which uses a different calculation base excluding employees in the time asset bond withdrawal phase, vocational trainees, partial-retirement passive-phase employees, and the Chinese joint ventures.

Reference: page 383

Volkswagen reports that 83% of employees are covered by the Group's health and safety management system based on legal requirements and/or recognized standards, and 46% by a system audited or certified by an external party. There were four deaths in the reporting year: three concerned Volkswagen Group employees and one concerned other workers, such as value-chain workers at Group sites. Employees had 10,819 recordable work-related accidents, equating to a total recordable injury rate (TRIR) of 11.7 (significant accidents multiplied by 1 million divided by total hours worked). The lost time injury frequency rate (LTIFR) for employees was 6.4 (prior year 3.6), though comparability is limited by a change in scope and methodology. At year-end 2024, 80 Group production sites (prior year 72) were ISO 45001 certified, covering 74% of employees at large production sites.

Reference: page 385

Volkswagen reports an unadjusted Gender Pay Gap of 13 percent in the reporting year, defined as the percentage difference in average gross hourly pay between men and women without taking structural differences into account. It is calculated as the difference between average earnings of male and female employees, divided by the average hourly earnings of male employees and multiplied by 100. Average hourly earnings per gender are based on annual total gross remuneration, including remuneration for work performed and for lost hours and absences, divided by annual working hours including overtime. The adjusted Gender Pay Gap, which accounts for qualification, experience, and position, is usually significantly lower. The ratio between the annual total gross remuneration of the highest-paid individual and the median for all other employees was around 195, calculated using an approximation method based on median remuneration.

Reference: page 389

Volkswagen reports that 3,555 reports were received through the investigation offices in the reporting year. Of cases treated as potential serious regulatory violations, 37 concerned discrimination and/or harassment, of which 22 were confirmed as serious violations. The disciplinary statistics recorded 250 sanctioned cases in the discrimination, bullying, stalking, and sexual harassment clusters; accounting for duplication with confirmed serious violations, a total of 257 cases regarding discrimination and harassment were identified. A further 15 cases concerned other workforce issues, of which two were confirmed. Total fines, penalties, and compensation for discrimination including harassment were 9 thousand euros. Potential LkSG relevance was identified for 15 reports, but there were no confirmed violations of LkSG-protected human rights and no cases of severe human rights violations under the ESRS, with no associated fines or penalties.

Reference: page 395

The Volkswagen Group developed the Responsible Supply Chain (ReSC) system management policy in Procurement to meet human rights and environmental due diligence obligations toward value chain workers. It applies to all direct suppliers, upstream and downstream, and to indirect suppliers depending on risk. The policy aims to avoid and minimize negative impacts on working conditions and other work-related rights such as child labor, forced labor, adequate housing, and water and sanitation, while promoting positive impacts and equal treatment. Expectations are set in the Code of Conduct for Business Partners, based on the OECD Guidelines, the UN Guiding Principles and ILO conventions. The ReSC system comprises risk analysis, standard actions and deep-dive actions. The board member for Brand Group Core is ultimately responsible.

Reference: page 398

The Volkswagen Group uses various formats to incorporate the views of value chain workers when fulfilling its human rights due diligence obligations. The Head of Group Procurement Sustainability holds overarching operational responsibility. Engagement occurs through multi-stakeholder initiatives and local projects such as the NAP automotive industry dialogue, the Responsible Mica Initiative, Cobalt for Development and the Responsible Lithium Partnership, often working with NGOs and trade union associations. The Group also took part in external events including a UN Global Compact Living Wages Roundtable. Through the CASCADE project in Indonesia, workers' views are gathered via interviews and questionnaires. Supplier audits collect worker views through anonymous surveys, and the supply chain grievance mechanism lets workers and their representatives report problems at any time. Findings feed into risk analysis and action development.

Reference: page 400

The whistleblower system is the central complaint procedure for the Volkswagen Group, coordinated by the Central Investigation Office in Wolfsburg. Employees, business partners, customers and third parties can report potential breaches, including human rights and environmental violations, anonymously if they choose. Reporting channels and rules of procedure are publicly accessible. Potential supplier violations or breaches of the Code of Conduct for Business Partners are forwarded to the supply chain grievance mechanism for investigation, logged in an IT system and documented. Violations are categorized by severity, and measures introduced accordingly, including temporarily blocking or terminating suppliers in serious cases. Effectiveness of remedial actions is reviewed case by case. Whistleblowers are protected from discrimination and reprisals. No actions currently analyze whether workers are aware of or trust the mechanism.

Reference: page 401

In 2024 the Volkswagen Group took standard and deep-dive actions within the ReSC system across a supply chain of more than 66,000 supplier sites in over 95 countries. A regular risk analysis classifies each supplier as low, medium or high risk and assigns a package of actions. Standard actions include confirmation of the Code of Conduct for Business Partners, the supply chain grievance mechanism (213 reports handled), media screening (over 39,500 direct suppliers, 89% of procurement volume), the S-Rating (14,709 ratings, 14,682 positive, 28 rated C), and training (5,129 staff participations, 9,818 suppliers trained). Deep-dive actions comprise the human rights focus system addressing forced labor, living wages and supplier management, and the raw materials due diligence management system covering 18 high-risk raw materials, plus projects such as Cobalt for Development, CASCADE and the Responsible Mica Initiative.

Reference: page 410

The ReSC system aims to avoid or minimize negative impacts on workers along the supply chain and directly serves the regenerate+ sustainability strategy. To measure progress, the Volkswagen Group set a relative target that, in terms of sales revenue, more than 95% of its direct suppliers have a positive S-Rating (A or B rating) by 2040, with an intermediate target of 85% in 2025. The S-Rating methodology, comprising an initial risk analysis, a standardized self-assessment questionnaire and risk-based audits, underpins the target. The target was set by an interdisciplinary working group; value chain workers are not involved in formulating or pursuing it. Achievement is monitored through the Group TOP 10 program. The share of sales revenue from suppliers with a positive S-Rating was 79% in 2023 and 83% in 2024.

Reference: page 417

To continuously reduce the number and severity of road traffic accidents involving its vehicles, the Volkswagen Group has set up interlinked management systems forming a Group-wide governance policy for vehicle safety. This addresses three levels: legal requirements, internal safety provisions and consumer protection standards. A Board-approved safety strategy works toward a high level of protection for customers through active (accident prevention) and passive/integral safety. The automotive cybersecurity management system (ACSMS) Group policy mitigates the risk of unauthorized access to vehicles and digital offerings, meeting UNECE regulation UN-R 155, with effectiveness confirmed by type approval authorities and annual monitoring audits. The product safety and conformity Group policy defines uniform standards for observing products placed on the market and averting risks. Responsibility rests with manufacturing brands and full-function companies via their product safety committees (APS).

Reference: page 419

To understand the interests and perspectives of its vehicle users, the Volkswagen Group works at brand level with national and international consumer protection organizations as credible proxies for users. The AKS (Safety System Working Group) coordinates cooperation with consumer protection authorities and industry groups on safety matters. The Group cooperates with the Insurance Institute for Highway Safety, the China Insurance Safety Index and New Car Assessment Program (NCAP) associations. Brands maintain contact partners or liaison offices for these organizations, and information from NCAP road maps feeds into the safety strategy and product development. Effectiveness is verified through vehicle ratings such as NCAP star ratings. Two further forms of dialog with customers affected by a security matter or cybersecurity failings exist within passive product observation, described under remedial processes and reporting channels.

Reference: page 419

Indications of safety-relevant matters from active or passive product observation are analyzed by divisions such as Technical Development and Production. Confirmed cases are referred to the product safety committee (APS), which decides on measures such as recall campaigns, workshop service campaigns, extended warranties or production halts, implemented and coordinated by the Product Safety department. Affected vehicle owners are informed by post or at the workshop. For cybersecurity, customers contact authorized dealerships, the customer hotline, or a dedicated security contact point, with cases forwarded to Incident Management and handled via the car security incident process. The whistleblower system can also report product safety and registration breaches. Customers can use e-mail, telephone hotlines and brand-specific vulnerability addresses. Each brand assesses the effectiveness of its channels. No Group-level review checks whether customers know, trust or are protected when using the channels.

Reference: page 421

Beyond its policies, the Volkswagen Group acts to keep vehicle safety and security technology up to date, researching safety, studying safety-relevant issues within the AKS, and integrating content into the Product Development Process (PEP). Actions exceeding legal minimum standards are regarded as positive contributions to vehicle safety. The cross-group AKS coordinates cross-brand safety requirements through quarterly meetings and 19 topic-specific working groups covering areas such as child safety, pedestrian protection, e-mobility and airbags. Safety objectives are embedded into the PEP via technical product descriptions. Group Accident Research investigates topics guided by a zero serious injuries or fatalities vision. The car security incident process (CSI) identifies, assesses and rectifies cybersecurity incidents through lifecycle monitoring. A comprehensive product observation system performs active and passive observation to identify safety risks early.

Reference: page 424

No measurable, outcome-oriented targets within the meaning of the ESRS are defined in relation to vehicle safety. The effectiveness of the policies and actions related to the positive and negative impacts identified through the double materiality assessment, performed this year for the first time, is currently not monitored. Nevertheless, the sum of the policies and actions contributes to the Group's efforts to ensure road traffic safety for customers, pursuing the vision of the safety strategy. Effectiveness is tracked in product development through compliance with internal and external safety regulations and monitoring of vehicle ratings such as Euro NCAP star ratings. Group Accident Research assesses safety technology effectiveness via a 24/7 on-call accident logging service and accident databases including GIDAS. The car security incident process runs a lessons learned review after incidents.

Reference: page 426

The Volkswagen Group Essentials and Code of Conduct define the shared values that form the basis of its corporate culture. The Group Chief Integrity and Compliance Officer owns the Code, with brands handling local rollout. Code of Conduct training repeats every three years for non-production staff and every four years in production areas; at year-end 2024, 261,707 employees (97% of those eligible) held a valid qualification. An updated Code of Conduct 3.0, then 3.1 covering whistleblower reporting channels, was published in 2024. An independent, confidential whistleblower system run by the Central Investigation Offices accepts reports in all languages around the clock and protects whistleblowers from reprisals. A strict zero-tolerance policy against corruption is anchored in the Code of Conduct and anti-corruption guideline.

Reference: page 441

The Volkswagen Group describes partnership- and trust-based supplier relationships managed through its regenerate+ strategy and the responsible supply chain system (ReSC). Risk analysis is performed before contract award based on suppliers' business models, with packages of measures assigned by risk classification. The Code of Conduct for Business Partners is binding for suppliers, sales partners and other B2B partners, and product-specific specifications set requirements such as supply chain transparency for cobalt, nickel, lithium and natural graphite. The S-Rating tool, in place since 2019, assesses suppliers with high sustainability risk. The Group aims for over 95% of direct suppliers by sales revenue to hold a positive S-Rating by 2040, with an interim target of 85% of procurement volume by 2025.

Reference: page 433

The Volkswagen Group pursues a strict zero-tolerance policy against corruption, anchored in its anti-corruption guideline and Codes of Conduct. Prevention rests on the internal compliance risk assessment (ICRA), which assigns companies low, medium or high risk profiles and corresponding measures. Risk-based anti-corruption and anti-money-laundering training is mandatory for high-risk companies; implementation in the Group's defined functions-at-risk reached 100% (97.3% in the Porsche AG Group). Senior managers are certified on the Code every two years and Board members receive in-depth one-off training. Business partner due diligence reviews sales partners' integrity through media screenings, sanction-list checks and automated daily monitoring. Suspected cases are reported via the whistleblower system and investigated independently of management, with investigation offices separate from operations.

Reference: page 433

The Volkswagen Group's investigation offices determine the number and type of identified corruption cases, covering corruption, bribery, fraud, extortion, collusion and money laundering. In 2024, the investigation offices received 3,555 reports in total. For controlled companies, 5 cases of corruption or bribery were ascertained in 2024 (including fraud, extortion, collusion and money laundering). In fiscal year 2024 the Group became aware that one former Group employee had been convicted of violating anti-corruption and anti-bribery laws, recorded as 1 conviction; the underlying breach came to light in 2022 and the employee had left the company in 2021. The Group is not aware of any fines connected with a conviction in fiscal year 2024.

Reference: page 437

Lobbying is organized centrally on principles of openness, transparency, responsibility and neutrality toward political parties, with any unfair influence prohibited under the Code of Conduct. Governance rests on the internal Public Affairs Group Policy and a one-voice policy; the Head of Public Affairs holds process responsibility, chairs a cross-brand steering committee and regularly informs the Board of Management. Eleven Group entities are registered in the German Bundestag Lobbying Register and four in the EU Transparency Register. Focus issues include e-mobility, battery regulation, trade, cybersecurity, automated driving and climate policy. The value of financial and in-kind political contributions made directly and indirectly by fully consolidated companies amounted to 92 thousand euros in 2024, none broken down by region except in the USA.

Reference: page 443

Standard procurement conditions of Volkswagen AG and other Group companies govern payment terms with suppliers and are publicly available. For Volkswagen AG suppliers, payment is made within 30 days; terms for other brands and companies range from 30 to 120 days in compliance with national legal requirements. Standard terms generally apply, with individual negotiated deviations possible and no standard deviation for a particular supplier group. On average, the Volkswagen Group takes 53 days to pay invoices, calculated using a days payable outstanding (DPO) definition also used for internal control. As of December 31, 2024, a small number of court-ordered summary proceedings for late payment were pending against the large publicly traded German Group companies, with year-end amounts not significant.